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In the current year, the CAR Partnership received revenues of $400,000 and paid the following amounts: $160,000 in rent, utilities, and salaries; a $40,000 guaranteed payment to partner Ryan; $20,000 to partner Amy for consulting services; and a $40,000 distribution to 25% partner Cameron. In addition, the partnership realized a $12,000 net long­term capital gain. Cameron's basis in his partnership interest was $60,000 at the beginning of the year, and included his $25,000 share of partnership liabilities. At the end of the year, his share of partnership liabilities was $15,000. a. How much income must Cameron report for the tax year? b. What is Cameron's basis in the partnership interest at the end of the year?

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j. $45,000 ordinary income and $3,000 LT...

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Sharon contributed property to the newly formed QRST Partnership. The property had a $100,000 adjusted basis to Sharon and a $160,000 fair market value on the contribution date. The property was also encumbered by a $120,000 nonrecourse debt, which was transferred to the partnership on that date. Another partner, Rochelle, shares 30% of the partnership income, gain, loss, deduction, and credit. Under IRS regulations, Rochelle's share of the nonrecourse debt for basis purposes is:


A) $20,000.
B) $30,000.
C) $36,000.
D) $100,000.
E) $120,000.

F) A) and E)
G) A) and D)

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Zach's partnership interest basis is $100,000. Zach receives a proportionate, liquidating distribution from a liquidating partnership of $50,000 cash and inventory having a basis of $20,000 to the partnership and a fair market value of $30,000. Zach assigns a basis of $20,000 to the inventory and recognizes a $30,000 loss.

A) True
B) False

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If a partnership allocates losses to the partners, the partners must first apply the passive loss limitations, then the basis limitation, and finally the at-risk limitations. If all three hurdles are met, the partner may deduct the loss.

A) True
B) False

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A partnership cannot use the cash method of accounting if one of the partners is a C corporation.

A) True
B) False

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Your client owns a parcel of land that has depreciated in value. He wants to know if there is a way he can contribute the property to his partnership, have the partnership sell the property, and convert the existing capital loss into an ordinary loss. He also wants to know if part of the loss would be allocated to his other partners. What is your reaction?

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In the short run, it would not be possible to convert the capital loss into an ordinary loss. If the client can wait more than five years for the partnership to sell the property, the character of the loss would be determined by reference to the partnership's use of the land. The built­in (precontribution) loss would be allocated to the client and any loss arising after the contribution date would be allocated according to the provisions in the partnership agreement. Section 724 provides that when property is sold by a partnership at a loss within five years of the date the property is contributed, any built-in capital loss at the contribution date remains a capital loss, regardless of the partnership's use of the property. For example, even if the land was considered inventory by the partnership rather than a capital asset, sale of that land within five years would result in a capital loss to the extent of the built-in loss at the contribution date. When a partner contributes property to a partnership, any built-in gain or loss must be tracked and allocated to the contributing partner under § 704(c). Therefore, the built­in loss would be allocated to the client when the property is eventually sold.

Rebecca is a limited partner in the RST Partnership, which is not publicly traded. Her allocable share of RST's passive ordinary losses from a nonrealty activity for the current year is ($60,000) . Rebecca has a $40,000 adjusted basis (outside basis) for her interest in RST (before deduction of any of the passive losses) . Her amount "at risk" under § 465 is $30,000 (before deduction of any of the passive losses) . She also has $25,000 of passive income from other sources. How much of her ($60,000) allocable loss can Rebecca deduct on her current year's tax return?


A) $25,000.
B) $30,000.
C) $40,000.
D) $60,000.
E) None of the above.

F) A) and B)
G) B) and E)

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The taxable income of a partnership flows through to the partners, who report the income on their tax returns.

A) True
B) False

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In the current year, Derek formed an equal partnership with Cody. Derek contributed land with an adjusted basis of $110,000 and a fair market value of $200,000. Derek also contributed $50,000 cash to the partnership. Cody contributed land with an adjusted basis of $80,000 and a fair market value of $230,000. The land contributed by Derek was encumbered by a $60,000 nonrecourse debt. The land contributed by Cody was encumbered by $40,000 of nonrecourse debt. Assume the partners share debt equally. Immediately after the formation, what is the basis of Cody's partnership interest?

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$90,000. Cody's basis is determined as f...

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A distribution can be "proportionate" (as defined for purposes of Subchapter K) even if only one partner receives assets from the partnership.

A) True
B) False

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The ELF Partnership distributed $20,000 cash to Emma in a proportionate, nonliquidating distribution. Emma's basis in her partnership interest was $12,000 immediately before the distribution. As a result of the distribution, Emma's basis is reduced to $0 and she recognizes an $8,000 gain.

A) True
B) False

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True

ABC LLC reported the following items on the LLC's Schedule K: ordinary income, $100,000; interest income, $3,000; long-term capital loss, ($4,000) ; charitable contributions, $1,000; post-1986 depreciation adjustment, $10,000; and cash distributions to partners, $50,000. How much will ABC show as net income (loss) on its Analysis of Income (Loss) ?


A) $68,000.
B) $78,000.
C) $95,000.
D) $98,000.
E) $102,000.

F) C) and E)
G) A) and B)

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Match each of the following statements with the terms below that provide the best definition. -Disguised sale


A) Organizational choice of many large accounting firms.
B) Partner's percentage allocation of current operating income.
C) Might affect any two partners' tax liabilities in different ways.
D) Brokerage and registration fees incurred for promoting and marketing partnership interests.
E) Transfer of asset to partnership followed by immediate distribution of cash to partner.
F) Must have at least one general and one limited partner.
G) All partners are jointly and severally liable for entity debts.
H) Theory treating the partner and partnership as separate economic units.
I) Partner's basis in partnership interest after tax­free contribution of asset to partnership.
J) Partnership's basis in asset after tax­free contribution of asset to partnership.
K) Owners are "members."
L) Theory treating the partnership as a collection of taxpayers joined in an agency relationship.
M) Allows many unincorporated entities to select their Federal tax status.
N) No correct match provided.

O) C) and G)
P) H) and N)

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Misha receives a proportionate nonliquidating distribution when the basis of her partnership interest is $60,000. The distribution consists of $80,000 cash and inventory (adjusted basis to the partnership of $10,000, fair market value of $20,000) . How much gain or loss does Misha recognize, and what is her basis in the distributed inventory and in her partnership interest following the distribution?


A) $0 gain or loss; $10,000 basis in inventory; $0 basis in partnership interest.
B) $0 gain or loss; $20,000 basis in inventory; $50,000 basis in partnership interest.
C) $20,000 capital gain; $0 basis in inventory; $0 basis in partnership interest.
D) $20,000 capital gain; $10,000 basis in inventory; $0 basis in partnership interest.
E) $20,000 ordinary income; $0 basis in inventory; $20,000 basis in partnership interest.

F) A) and B)
G) A) and E)

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Which of the following is an election or calculation made by the partner rather than the partnership?


A) Calculation of a § 199 deduction amount.
B) Whether to capitalize, amortize, or expense research and experimental costs.
C) The partnership's overall accounting method.
D) Whether to claim a § 179 deduction related to property acquired by the partnership.
E) All of the above elections are made by the partnership.

F) A) and E)
G) B) and C)

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Landis received $90,000 cash and a capital asset (basis of $50,000, fair market value of $60,000) in a proportionate liquidating distribution. His basis in his partnership interest was $120,000 prior to the distribution. How much gain or loss does Landis recognize and what is his basis in the asset received?


A) $0 gain or loss; $30,000 basis.
B) $0 gain or loss; $50,000 basis.
C) $0 gain or loss; $60,000 basis.
D) $20,000 gain; $50,000 basis.
E) $30,000 gain; $60,000 basis.

F) A) and B)
G) A) and D)

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A limited liability company generally provides limited liability for those owners that are not active in the management of the LLC but requires owner-managers of the LLC to have unlimited personal liability for LLC debts.

A) True
B) False

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A limited partnership offers all partners protection from claims by the LP's creditors.

A) True
B) False

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False

Nicholas is a 25% owner in the DDBN LLC (a calendar year entity) . At the end of the last tax year, Nicholas's basis in his interest was $50,000, including his $20,000 share of LLC liabilities. On July 1 of the current tax year, Nicholas sells his LLC interest to Anna for $80,000 cash. In addition, Anna assumes Nicholas's share of LLC liabilities, which, at that date, was $15,000. During the current tax year, DDBN's taxable income is $120,000 (earned evenly during the year) . Nicholas's share of the LLC's unrealized receivables is valued at $6,000 ($0 basis) . At the sale date, what is Nicholas's basis in his LLC interest, how much gain or loss must he recognize, and what is the character of the gain or loss?


A) $45,000 basis; $6,000 ordinary income; $44,000 capital gain.
B) $60,000 basis; $6,000 ordinary income; $29,000 capital gain.
C) $60,000 basis; $35,000 capital gain.
D) $75,000 basis; $0 ordinary income; $20,000 capital gain.
E) $75,000 basis; $6,000 ordinary income; $14,000 capital gain.

F) C) and E)
G) C) and D)

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Match each of the following statements with the terms below that provide the best definition. -Precontribution gain


A) Adjusted basis of each partnership asset.
B) Operating expenses incurred after entity is formed but before it begins doing business.
C) Each partner's basis in the partnership.
D) Reconciles book income to "taxable income."
E) Tax accounting election made by partnership.
F) Tax accounting calculation made by partner.
G) Tax accounting election made by partner.
H) Does not include liabilities.
I) Designed to prevent excessive deferral of taxation of partnership income.
J) Amount that may be received by partner for performance of services for the partnership.
K) Computation that determines the way recourse debt is shared.
L) Will eventually be allocated to partner making tax-free property contribution to partnership.
M) Partner's share of partnership items.
N) Must generally be satisfied by any allocation to the partners.
O) Justification for a tax year other than the required taxable year.
P) No correct match is provided.

Q) C) and F)
R) G) and M)

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